public, and the environment. SC&A has performed a number of accident
analyses, including:

- Special studies of DOE facility safety for DNFSB.

- Nuclear power plant safety analyses for the NRC and the Congressional
OTA.

- Accident analyses in support of the development of Protective Action
Guides for the EPA.

- Chernobyl studies for EPA.

- Criticality evaluations related to both LLW and HLW management.

- Criticality evaluations of the October 16, 1959 criticality accident at INEL.
Data Collection, Analysis, and Evaluation

SC&A performed several studies pertaining to the collection of data for use in
dose/risk assessment and regulatory compliance. The studies included:

- The development of guidance for data collection for use in risk
assessments for EPA.

- Guidance on evaluating the usability of data for risk assessment for EPA.

- The review of data gathered by others at numerous DOE and non-DOE
Sites.

- The collection of field data from numerous sites for use in dose/risk
assessments and site closeout.

- The collection of license termination data from the Nuclear Energy
Institute (NED, EPRI, and ORISE in support of NRC clearance
investigations.

- Collection and analysis of environmental samples collected from the
Republic of the Marshall Islands.

Cleanup Technologies
In addition to the review of technologies performed for OTA and EPA, SC&A has

developed a soil washing system for EPA for sites containing large volumes of
soil contaminated with slightly elevated levels of naturally occurring

SC&A

5-15 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

| ‘Audit Number: Claim Number:

Date: Page of

Description of Technical Elements of Review | Yes/No/

NA

Comments

Initials

Do assumptions used in determining
occupational medical exposure geometry
give the benefit of doubt to the claimant?

CAALI

Are assumptions used to determine the most
credible geometry for environmental
exposure appropriate? (§4.4.3)

CLlij

Do assumptions used in determining
environmental exposure geometry give the
benefit of doubt to the claimant?

Dose

C.2_ External Dose Calculations: Verify external dose calculations are appropriate for purposes of
determination of POC using NIOSH-IREP. (Parenthetical number represents the section within the “Ext

Reconstruction Implementation Guideline” (OCAS-IG-001

conducting the appropriate portion of the dose reconstruction.)

) that provides detailed methodology for

ternal

C21

Are calculations in the initial dose assessment
(ie., rough estimate of exposure) for
determining whether the case falls into a very
low or very high potential exposure category
appropriate and correct? (§1.4)

Photon Dose Reconstruction Using Monitoring

Are calculations of photon dose using
monitoring data (i.e., dosimeters)
appropriate and correct? (§2.1.1)

C22.b Are calculations of dosimeter dose
uncertainty associated with photon exposure
appropriate and correct? (§2.1.1.3)

C.2.2.¢ Are calculations of dose for incomplete/

missing photon monitoring records
appropriate and correct? (§2.1.2)



SC&A was a prime contractor to EPA ORIA over a 15-year period (1986 to 2000). EPA 402-B-
02-001 (October 2002) lists over 700 reports published by ORIA. SC&A was a principal
contributor to many of those reports dealing with radiological issues. Noteworthy among those
reports include:

Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), 402-
R-97-016

Environmental Characteristics of EPA, NRC, and DOE Sites Contaminated with
Radioactive Substances, 402-R-93-011, March 1993

Computer Models Used to Support Cleanup Decision Making at Hazardous and
Radioactive Waste Sites, 402-R-93-005, March 1993

Risk Assessment Guidance for Superfund (RAGS): Part A (Volume 1 - Human
Health Evaluation Manual), 540-1-89-002, December 1989

Radiation Site Cleanup Regulations: Technical Support Document for the
Development of Radionuclide Cleanup Levels for Soil, 402-R-96-011, Volumes
A,B,C,D

Radiation Exposure and Risk Assessment Manual (RERAM), 402-R-96-016

Background Information Document to Support NESHAPS Rulemaking on
Nuclear Power Reactors, 402-R-94-015

Fact Sheet: Computer Models Used to Support Cleanup Decision Making at
Hazardous and Radioactive Waste Sites, 540-F-94-022

Fact Sheet: Environmental Characteristics of EPA, NRC, and DOE Sites
Contaminated with Radioactive Substances, 540-F-94-023

Fact Sheet: Environmental Pathway Models — Ground-Water Modeling in
Support of Remedial Decision Making at Sites Contaminated with Radioactive
Material, 540-F-94-024

Fact Sheet: A Technical Guide to Ground-Water Model Selection at Sites
Contaminated with Radioactive Substances, 540-F-94-025

A Technical Guide to Ground-Water Model Selection at Sites Contaminated with
Radioactive Substances, 402-R-94-012 (prepared as a cooperative effort by EPA,
the NRC Office of Nuclear Material Safety and Safeguards, and the DOE Office
of Environmental Restoration)

Evaluating Technical Capabilities of Groundwater Models Used to Support the
Cleanup of Low-Level Radioactive Waste Sites, 402-R-93-010

SC&A

5-9 Sol. No. 2003-N-00768


APPENDIX C

DOSE RECONSTRUCTION AUDIT REPORT

Page of

Audit Number:

| Claim Number:

| Date:

Auditor(s)/Area of Review:

Audit Record Summary (Describe below what records you examined, person contacted/interviewed, what
conclusions were drawn, and how you arrived at your conclusions): .

List the type of records reviewed (e.g., administrative record):

List of persons contacted/interviewed:

List of new documents identified: (Attach a copy of all documents not included in the original dose reconstruction

to this report.)

Audit Conclusions: Agree/Disagree
‘Note: Attach all audit checklists and
supporting documents.)

Agree: nitial)
Include any additional comments
in ‘General Comments’ below.

Disagree: (Initial)
Additional discussion should be
provided in the next section.

Provide a summary discussion of reasons for disagreeing with the dose reconstruction results:
(Attach all calculations, notes, reports, etc. used in your conclusions.)

General Comments:

iz

Signature of Auditor(s):

Area of Review:

Date:

—

BASIC INDIVIDUAL DOSE RECONSTRUCTION

Ci





BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

C.1.10.b

Are assumptions for the uncertainty analysis
associated with reconstructing electron dose
using co-worker data appropriate?
(§2.2.1.3)

C.1.10.c

‘Are assumptions incorporated in the
reconstruction of electron dose using survey
data appropriate? (§3.3.2)

C1100

Are assumptions for determining
uncertainty associated with reconstructing
electron dose using survey data appropriate
(83.3.2.3)

C.1.10.€

Are assumptions incorporated in the
reconstruction of electron dose using source
term data appropriate? (§3.3.3)

C.1.10£

‘Are assumptions for the uncertainty analysis
associated with reconstructing electron dose
using source term data appropriate?
(§3.3.3.3)

C.1.10.g

Are assumptions incorporated in the
reconstruction of electron dose to non-
routine radiological workers using
radiological control limits appropriate?
(§3.3.4)

C.1.10.b

Are assumptions for the uncertainty
associated with reconstructing electron dose
using radiological control limits
appropriate?

C1104

‘Are conservative (claimant friendly)
assumptions used for reconstruction of
electron dose, when no monitoring data
were available?

C-12



radionuclides. The studies included an evaluation of the worker and public health
tisks associated with the technology.

Database Management and GIS Systems

SC&A has developed several large database management systems and GIS
systems in support of the performance of dose/risk assessment/management and
outreach programs.

Outreach Programs

Many of the risk assessment programs performed by SC&A have had large public
outreach components, which included the coordination of Jocal and national
workshops, the preparation of newsletters, information booklets, and videos. In
addition, SC&A interacts with the Federal Advisory Committee for the INEEL
dose reconstruction.

Epidemiologic Studies

SC&A performed pilot epidemiologic studies for:

- Workers at commercial nuclear power plants for EPRI.
- Indoor radon for EPA.

Dose/Risk Assessments in Support of Policy Decision making
SC&A performed nationwide screening studies to aid:

- The EPA Office of Policy, Planning and Evaluation to set national
priorities. .

- The NRC to evaluate nuclear power plant license renewal and clearance.

- The Nuclear Safety Oversight Committee to establish a nationwide
approach to safety.

- The OTA to evaluate nationwide cleanup strategies.

- The EPA to evaluate radon mitigation strategies.

5-16 Sol. No. 2003-N-00768


|||
BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials,
Review NA

B.2 Data Consistency: Assure that interview information is consistent with data used for dose estimate.

B.2.1 Is there consistency between the dates of

employment at all applicable facilities provided
by the claimant and the DOE/Contractor or
AWE site records?

B22 Is there consistency between the locations of
employment throughout the work history as
declared by the claimant and the
DOE/Contractor or AWE site records?

B23 Is there consistency between facility records
and radiation incidents identified by claimant?

B.2.4 Is there consistency between radiation
monitoring practices described by claimant and
site radiological monitoring protocols?

B25 Is there consistency between personnel
protection practices described by claimant and
site profile data?

=

B.2.6 Is there consistency between claimant’s
description of work practices and facility
procedures/records?

C4


APPENDIX C

DOSE RECONSTRUCTION AUDIT CHECKLISTS


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST |

Audit Number: Claim Number:

Date:

Page of |

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

tnt]

C.1.10j

Are conservative (claimant friendly)
assumptions used in the determination of
certainty associated with the reconstruction
electron dose, when no monitoring data
were available?

C1
C.liLa

Electron Dose Conversion to Organ Dose:
Are assumptions used to convert electron
dose to organ dose appropriate? ($4.3)

CLILD

Are assumptions used to convert electron
dose to organ dose conservative (claimant
friendly)?

CLA

Dose Conversion Factors Based on Exposure
Geometry:
Are assumptions used to determine the most.
credible geometries for dosimeter and
missed dose appropriate? ($4.4.1)

C.AALd

Do assumptions used in determining
geometries associated with dosimetry and
missed dose give the benefit of doubt to the
claimant?

C.Lile

Are assumptions used to determine
exposure geometry uncertainty associated
with specific job functions appropriate?
(84.5.2)

CALLE

Do assumptions used in determining
uncertainty associated with exposure
geometries for specific tasks give the
benefit of doubt to the claimant?

Cig

Are assumptions used to determine the most
credible geometry for occupational medical
exposure appropriate? (§4.4.2)

es ee a Ss |



Dose/risk assessments in support of the development of Protective Action
Guides and Derived Response Levels for the water pathways.

Dose/risk assessments of the discharge of produced water (water
containing elevated levels of naturally occurring radionuclides) from
coastal and offshore oil and gas drilling platforms in the Gulf of Mexico.
Dose/risk assessments in support of the drinking water standards.

Assessments of the radiosensitivity of aquatic organisms.

. Review and Development of Multimedia Models and Computer Codes for Use in
Risk Assessment

Support in the development of regulations and guidelines for the EPA required
extensive model review and development, including:

The review of 25 multimedia models for possible use in support of the soil
cleanup rule. This resulted in the selection and use of RESRAD,
PRESTO, and HHEM Part B.

The verification and validation of AIRDOS-EPA for use in support of the
radionuclide NESHAPS.

The development of guidance on the selection and use of groundwater
flow and transport models for use in support of remedial decision making
at radioactively contaminated sites.

Participation in multimedia model evaluation for the DOE Programmatic
Environmental Impact Statement (PEIS) for the DOE Environmental
Restoration program.

Development of computer codes to supplement existing codes for
assessing the doses and risks to workers and the public from recycling and
site cleanup.

. Decontamination/Decommissioning/Recycling Studies

Both the NRC and EPA are engaged in the promulgation of regulations pertaining
to the decommissioning of structures and the possible recycling of metal and
concrete. SC&A has performed several worker and public health dose/risk
assessment studies for both agencies in support of these rulemakings.

SC&A

5-13 Sol. No. 2003-N-00768


of members of the public on and offsite since the commencement of operations in 1949. This
bibliographic database was designed to facilitate research into the historical non-occupational
exposures at INEEL. Based on this experience, SC&A understands the challenges associated
with the retrieval of critical historical records related to dose reconstruction.

On June 21, 2002, CDC authorized SC&A, in cooperation with SENES Oak Ridge, to proceed
with a research project that included:

. Calculation of the chronic and episodic airborne radionuclide releases from the
Idaho Chemical Processing Plant (ICPP) for the years 1957, 1958, and 1959, from
the criticality accident that occurred in October 1959, and from the series of 31
Initial Engine Tests of the Aircraft Nuclear Propulsion Program (ANP).

° Determination of the historical doses to members of the public both on and offsite
from these releases.

The project also involves the search for additional records as required for the above research and.
adding them to the bibliographic database, attending meetings of the INEEL Health Effects
Subcommittee (a Federal Advisory Committee), and preparing fact sheets regarding the project
and our findings. The results of this research are to be used by CDC to determine the need for
follow-up investigations into the potential impact of these radiation doses on public health.

5.4 Dose Reconstruction Support to the Republic of the Marshall Islands

SC&A provided technical support to the Office of the Public Advocate, Central Government, and
the Local Government Councils of Enewetak, Bikini, Rongelap, and Utrik Atolls of the
Republic of the Marshall Islands in matters relating to the resettlement of the northern atolls and
public health and land claims compensation due to radioactive contamination and radiation
exposures resulting from nuclear weapons testing in the Central Pacific. These services included
the following: .

. Evaluate the current and future, and actual and potential, radiation doses and
radiological health risks to the critical population groups and the average members
of the populations of the northern atolls of the Marshall Islands from
radionuclides in the environment due to nuclear weapons testing.

The evaluations used existing data (supplemented in some cases by confirmatory
sampling and analyses) characterizing the radionuclide concentrations in soil,
foods, air, and water to develop three-dimensional representations of the
contamination profiles on the islands. Radiation doses and health risks were then
derived using the methodologies recommended by the EPA and site specific
information regarding diets, living habits, and environmental transfer constants on
the islands.

SC&A 5-5 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials}
Review NA

C174 ‘Are assumptions for determining

uncertainty associated with reconstructing
neutron dose using survey data appropriate
(83.2.2.3)

PH

C17.

Are assumptions incorporated in the
reconstruction of neutron dose using source
term data appropriate? (§3.2.3)

CATE

Are assumptions for the uncertainty analysis
associated with reconstructing neutron dose.
using source term data appropriate?
(§3.2.3.3)

C.1.7.g

Are conservative (claimant friendly)
assumptions used for reconstruction of
neutron dose, when no monitoring data
were available?

CATb

Are conservative (claimant friendly)
assumptions used in the determination of
certainty associated with the reconstruction
neutron dose, when no monitoring data
were available?

C.18
C18.

Neutron Dose Conversion to Organ Dose:

Are assumptions used to convert area
monitoring data associated with neutron
dose to organ dose appropriate? (§4.2.1)

C.1.8.b

Are assumptions used to convert personal
monitoring data associated with neutron
dose to organ dose appropriate? (§4.2.2)

C.1.8.c

Are conservative (claimant friendly)
assumptions used to convert neutron dose to
organ dose?



BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page

Area of
Review

of

Description of Technical Elements of Review

Yes/No/
NA

Comments

C.14c

Are assumptions incorporated in the
reconstruction of photon dose using survey
data appropriate? (§3.1.2)

C14.

Are assumptions for determining
uncertainty associated with reconstructing
photon dose using survey data appropriate?
(§3.1.2.3)

C.1.4e

Are assumptions incorporated in the
reconstruction of photon dose using source
term data appropriate? (§3.1.3)

CAE

Are assumptions for the uncertainty analysis
associated with reconstructing photon dose
using source term data appropriate?
(§3.1.3.3)

C.1.4g

Are assumptions incorporated in the
reconstruction of photon dose using control
limits appropriate? (§3.1.4)

CA4h

Are assumptions for determining
uncertainty associated with reconstruction
photon dose using contro! limits
appropriate? (§3.1.4.3)

CAG

Are conservative (claimant friendly)
assumptions used for reconstruction of
photon dose, when no monitoring data were
available?

C145

Are conservative (claimant friendly)
assumptions used in the determination of
certainty associated with the reconstruction
photon dose, when no monitoring data were
available?

C7



Our private sector work has been limited primarily to the radiological characterization of
contaminated sites and providing heath physics oversight and closeout surveys. We have also
assisted many NRC licensees in obtaining and maintaining their NRC licensees. In its more than
20 years of existence, SC&A has performed work on approximately 225 contracts, including
more than 1,000 tasks for its clients.

5.1 Radiological Assessment Support to the NRC and the Nuclear Power Industry

SC&A has held 17 contracts with the NRC, either as a prime contractor or subcontractor, since
1981. Six of these contracts were completed or initiated within the past five years. Under these
contracts, SC&A fulfilled dozens of task orders, with support requirements spanning the entire
spectrum of assistance requested under this solicitation.

SC&A evaluated the impact of NRC-initiated multi-plant actions on worker radiation exposures.
A list of multi-plant actions potentially resulting in occupational radiation exposures was
compiled from the NRC “orange book" for the period 1979 through 1983. This list was
supplemented by the relevant I&E Bulletins over the same time period. The next step was to
divide the operating reactors into classes, based on distinguishing parameters, and to select
representative plants from each of the classes.

Occupational radiation exposure data were obtained from the Radiation Work Permits at ten
representative plants for tasks corresponding to the NRC multi-plant actions. The exposures
from these representative plants were used to estimate the total exposures at light water-cooled
reactors. The results were presented in a form which illustrates the contribution of dose from
NRC-initiated multi-plant actions to total worker dose. The report was published as
AIJF/NESP-033, Occupational Radiation Exposure Implications of NRC-Initiated Multi-Plant
Actions, March 1986.

In the early 1980s, the nuclear energy industry employed an increasing number of non-permanent
radiation workers at nuclear power plants, variously referred to as "temporary" or "transient"
workers. Little was known about these workers, aside from their radiation exposures, which
were alleged to be higher, on the average, than those of permanent station employees. SC&A
conducted a study to characterize the non-permanent radiation workers at nuclear power plants.
The workforce was subdivided into permanent station employees, non-station utility employees,
temporary station utility employees, permanent contractor employees, and temporary contractor
employees. For each category of workers, data were collected on numbers of individuals by
craft, age, sex, geographical origin, duration of employment, and radiation exposure.
Additionally, radiation exposures were evaluated by specific job, including steam generator
repair, control rod drive maintenance, decontamination, and waste management. Finally, the
training in radiation safety was assessed for both permanent and temporary workers.

In evaluating the job-specific radiation exposures, it was necessary to disaggregate radiation
work permits by worker category. Although this task was simplified at some plants through the
use of automated databases, tedious reviews were necessary at other plants. In total, one to three
years of exposure data were obtained for 15 units at nine stations operated by six utilities. The
work was published as a report entitled, "Characterization of the Temporary Radiation Work

SC&A 5-2 Sol. No. 2003-N-00768


5.0 CORPORATE EXPERIENCE

SC&A currently has approximately 30 employees and approximately 100 associates. More than
75 percent of SC&A’s professional staff have advanced degrees. The majority have 15 to 25
years experience solving scientific and technical problems and implementing solutions to
radiation and radiation-related issues. SC&A personnel are primarily engineers, health
physicists, chemists, and physicists. The engineering staff is composed of nuclear, chemical, and
environmental professionals, many with professional registration. About one-fourth of the health
physics staff are Certified Health Physicists, and almost all the chemists are radiochemists. Other
disciplines include computer science, metallurgy, and hydrology. The following presents
SC&A’s corporate organizational chart.

SC&A Organizational Chart

Sanford Cohen
President
f Executive Officer

Gregory Beronja Laurie Loomis
Vice President z Vice President
Chief Operating Officer ff Administrative Services

Nancy S. Johnson Linda Foley
Production Coordinator ‘Accounting Manager

John J. Mauro Charles (Chick) Phillips |g | William Ulicny, Manager [gj Patrick Kelly, Manager
Senior Vice President Vice President Radiation Field Quality Assurance

Consulting Division Laboratory Division Services Division Division

Since its founding, SC&A has provided primarily radiological consulting services to Federal
agencies under large, task order, cost plus fixed fee contracts. Our principal clients have been
and continue to be the CDC, the NRC, the EPA (particularly ORIA/EPA), and the Republic of
the Marshall Islands (RMI). We have also held large contracts with the DNFSB and the
Congressional Office of Technology Assessment (OTA). The important point is that our primary
business is providing the highest quality radiological consulting services to Federal agencies,
especially agencies that provide independent regulatory oversight to the DOE and its contractors.
From the perspective of being qualified for providing the services required by this contract, and
still being free of any real or perceived conflict of interest, SC&A is in a very unique position.
The only significant amount of work that we perform for DOE is laboratory services for some
DOE contractors, and we do no work for NIOSH.

SC&A 5-1 Sol. No. 2003-N-00768


High-Level Waste Studies

SC&A performed numerous studies for EPA on the risks associated with the
management of high-level radioactive waste (HLW). These studies included:

- Waste characterization.
- The review of performance assessment models.
- Uncertainty analysis.

- The evaluation of release and exposure scenarios, their probabilities, and
the associated radionuclide releases to the accessible environment.

- Waste transportation studies.
Uranium Mill Tailings

In addition to the NORM risk assessments, SC&A performed several studies in
support of the uranium mill tailings standards. These studies included the
modeling of the risks from radon, dust suspension, direct radiation, and the
contamination of groundwater.

Low-level Radioactive Waste (LLW)

SC&A assisted the EPA in the promulgation of 40 CFR 193. This work involved
revising PRESTO to reflect updated waste characteristics, site characteristics, and
disposal technologies. SC&A has also performed risk assessments in support of
the siting of LLW storage facilities for NRC licensees.

Radiation Worker Dose/Risk Assessment
SC&A performed several worker radiation dose studies in support of:

- The revised 10 CFR 20 for the NRC.

- Worker training requirements for the NRC.

- Radiation protection guidelines for EPA workers.

- Health physics consulting for NRC licensees.

- ALARA studies for NUMARC and AIF.

- Dose/risks to workers due to site cleanup at numerous NORM sites.

Safety Analysis and Emergency Planning
Except for the HLW studies, the above studies are oriented toward exposures

associated with normal, as opposed to transient or accident, conditions. Accidents
or severe external events can be the limiting scenario for the risks to workers, the

SC&A

5-14 Sol. No. 2003-N-00768


individual and collective dose assessments to determine the radiological impacts of alternatives
for the. clearance of materials and equipment. Both projects involve the development of Monte
Carlo-based multimedia dose assessment models for evaluating individual and collective doses to
workers and the public, including formal assessment of uncertainties and variabilities. The
models make extensive use of ICRP methodologies for performing internal and external
exposures.

5.2 Defense Nuclear Facilities Safety Board Support

SC&A was a technical support contractor to the DNFSB from 1993 through 1997. DNFSB was
established by Congress in 1989 as an independent agency to provide advice and
recommendations to the Secretary of Energy on public health and safety at DOE defense nuclear
facilities. Fourteen tasks were ordered during the four years that SC&A held the contract.
(DNFSB eventually brought the work in-house.)

SC&A developed a Standard Review Guide (SRG) on Radiological Training under the DNFSB
contract, which was intended to be the first of a series of guides that would comprehensively
relate to radiological protection. SC&A also reviewed several implementation guides under the
DOE rule on occupational radiation protection, 10 CFR Part 835, and compared them with
applicable commercial and government standards, assessing their technical content with the
guidance that has been given to commercial utilities. The lessons learned from these programs
provide insight into the strengths and limitations of historic DOE radiation protection programs
vis-a-vis NRC regulated programs.

It is important to note that all of these investigations that SC&A performed for our Government
clients required auditable QA/QC programs performed under fully documented pre-approved
Quality Management Plans and Quality Assurance project procedures which implemented those
plans for each project. Our documentation had to be complete, transparent, and was audited by
our clients on numerous occasions. During your review of our past performance on these
projects, you will have an opportunity to judge the responsiveness and quality of our work.

5.3 ° Dose Reconstruction Support to Centers for Disease Control

In January 1990, the Secretaries of the Departments of Energy (DOE) and Health and Human
Services (DHHS) signed a Memorandum of Understanding (MOU) transferring to DHHS
responsibility and funding for studies of chemical and radionuclide releases from DOE nuclear
facilities, and of potential exposures and health effects to the surrounding population. The
primary purpose of this transfer of responsibility was to avoid any perceived or actual conflict of
interest associated with DOE performing the historical dose evaluations for facilities for which it
has operational responsibility.

Under the authority of the MOU, the Radiation Studies Branch (RSB) of the CDC began its
independent investigations into the historical doses at the INEEL in 1992. The first phase of
these investigations began with the retrieval of approximately 15,000 boxes of records and the
creation of a bibliographic database containing titles and abstracts of reports, records, and
documents pertinent to the historical operations, radionuclide emissions, and radiation exposure

SC&A 5-4 Sol. No. 2003-N-00768


REVIEW CHECKLIST

‘Audit Number: Claim Number: Date: Page of
Auditor(s)/Area of Review:
Dose Reconstraction Analysis(s)/Area of Dose Reconstruction (External/Internal):

Area of |Description of Technical Elements of Review | Yes/No/ ‘Comments Tnitials

Review NA

A, DATA COLLECTION REVIEW PROCESS

A.1 Data Collection: Evaluate whether NIOSH received all requested data for the DOE or AWE site from any

relevant data source or repository. (Note: Follow protocols established in Volume 2, Section 3 of the proposal.)

ALI

Did NIOSH receive all requested data for the
DOE or AWE site from any relevant data
source (i.e., site/worker profile data from
sources such as DOE/AWE, CDC, DNFSB,
‘Congressional Records, etc.)?

A.2 Adequacy of Data: Evaluate whether the data used

by NIOSH for the case was adequate to make a

determination with regard to probability of causation. (Note: Follow protocols establish in Volume 2,
3 of proposal. Determining adequacy of data may require that the entire basic review checklist be completed first.)

Section

A21

Is there sufficient data (such as individual
monitoring, workplace monitoring, workplace
characterization, process description, co-worker
monitoring) for calculating/
interpolating/extrapolating external doses for
all periods of exposure, including monitored,
missing, and unmonitored periods?

A22

Is there sufficient information (such as co-
worker comparison data, area monitoring data,
‘instrument calibration, monitoring practice
procedures, etc.) to determine if the quality of
data used for determining POC is adequate?

C2


SC&A 424 Sol. No. 2003-N-00768


This particular task, which lasted two years at a cost of about $500,000, required
retrieval and in depth review of hundreds of recently declassified documents,
which included data logs, telegraph communications, redacted documents, hand
written reports, very old overflight radiological surveys, film badge readings,
results of radiological surveys performed using primitive and poorly calibrated
instrumentation, and the review of bioassay data that was sparse, used primitive
techniques, and was contradictory. We visited remote atolls of the Marshall
Islands and spent extensive periods of time (weeks) interviewing these people to
elicit their personal experience and recollection of events that took place almost
50 years ago. This experience is invaluable in terms of the lessons learned with
regard to what it means to reconstruct historical doses under difficult situations.

As a result of this work, we believe we have uncovered major discrepancies
between the whole body, thyroid, and GI tract doses experienced by the
Marshallese as compared to the doses reported by the Government at that time and
to this day. The people of the Marshall Islands have learned to trust us to
objectively report our findings and defend our work before government tribunals
and the DOE. We believe that, in providing these services, we have not only
earned the respect of the people of the Marshall Islands, but also our counterparts
at the DOE and the various independent consultants that have been reviewing our
work. The two key individuals that were responsible for this work, Drs.

, are key individuals on this proposed project for the
Advisory Board.

. Performance of MARSSIM radiological surveys for selected northern atolls for
the purpose of determining whether remediation is required or to certify that the
islands comply with the cleanup criteria.

This involved sending a survey team to collect samples of soil, water, and food
items on the Island of Ailuk. The samples were analyzed at SC&A’s laboratory in
Montgomery, Alabama and in the RMI laboratory in Majuro. Before analyzing
the samples in the Majuro lab, SC&A refurbished the lab, and installed and
calibrated new counting equipment. As part of the project, SC&A trained six
Marshallese in field sampling procedures and worked closely with Marshallese
laboratory personnel in performing sample analyses at the Majuro lab.

. Evaluation of the northern atolls for PCB contamination.

Concern was expressed by the people of Enewetak and Bikini that their atolls may
have also been contaminated with PCBs resulting from the facilities constructed
on Enewetak and the ships that were sunk in the lagoon of Bikini atoll. SC&A
collected soil, lagoon sediment, and fish and analyzed the samples for a broad
range of PCB congeners and trace heavy metals.

Our scope of work included defending our analyses before the Nuclear Claims Tribunal for
claims amounting to over $1 billion. On four separate occasions, SC&A consultants participated

SC&A 5-7 Sol. No. 2003-N-00768


Compare these radiation doses and health risks to the applicable radiation
protection standards.

The standards included the 15 mrem/yr EDE above background standard adopted
by the EPA and by the RMI for the cleanup of sites contaminated with radioactive
materials. SC&A also evaluated the doses against the 25 mrem/yr and 100
mrem/yr standards set forth in NRC regulations and recommended by the NCRP
and ICRP.

Derive soil cleanup levels.

This involved determining the combined average concentrations of Cs-137, Sr-90,
Pu-239/240, and Am-241 in soil in survey units, considering depth of
contamination, that provide a level of assurance that the resettled populations
and/or the existing populations on each island will not receive exposures in excess
of the EPA cleanup criteria of 15 mrem/yr above background to the reasonable
maximally exposed individual for all pathways of exposure.

Evaluate the costs and effectiveness of a broad range of alternative strategies for
the remediation of the islands to the EPA cleanup criteria.

The remediation strategies include the no action alternative, natural attenuation
with monitoring (including whole body counting, urinalysis, and environmental
radiological surveillance), food avoidance, island avoidance, soil removal,
application of soil additives to suppress the uptake of radionuclides by plants
(including the application of potassium and the application of clay-like additives
to soil), soil washing, and phytoremediation. Due to the location of the islands
and the unique environmental settings, cost analysis for each remediation strategy
required unit cost information unique to the Marshall Islands.

Reconstruction of the historical radiation exposures and associated health risks to
the people of the Marshall Islands from fallout from nuclear weapons testing.

This work involved the review of hundreds of recently declassified documents
characterizing bioassay data, film badge readings, radiation survey readings, aerial
survey overflight readings, fallout patterns, and the observed clinical effects of
fallout on the populations of the northern atolls. The dose reconstructions
included derivation of the doses to the average members of the populations and
members of the critical population groups each year from 1946 to the present.
These dose reconstructions were then compared to the applicable radiation
protection standards at the time for the purpose of assessing compensable “loss of
use” claims. SC&A also derived the time integrated collective doses to the
populations in support of claims compensation for adverse impacts on public
health. This involved monetizing the detriment caused by the exposures using a
broad range of methods adopted by the EPA, NRC, and other agencies for
monetizing health detriment.

SC&A

5-6 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST
Audit Number: Claim Number: Date: Page of

Description of Technical Elements of Review | Yes/No/ Comments Initials
NA

‘Are assumptions used to determine dose
associated with incomplete/missing neutron
monitoring data and associated neutron
energies appropriate? (§2.2.2)

C164 Are assumptions used in determining
‘uncertainty associated with
incomplete/missed neutron monitoring dose
appropriate? (§2.2.2.4)

C.1.6.¢ Are conservative (claimant friendly)
assumptions used in the calculation of
neutron dose/neutron energies using
monitoring data?

C.1.6.£ Are conservative (claimant friendly)
assumptions used in determining
uncertainty associated with neutron
monitoring dose?

Neutron Dose Reconstruction With NO
Monitoring Data:
Are assumptions incorporated in the
reconstruction of neutron dose using co-
worker data appropriate? (§3.2.1)

C.1.7.b Are assumptions for the uncertainty analysis
associated with reconstructing neutron dose
using co-worker data appropriate?
(§2.2.1.3)

C.A7.c Are assumptions incorporated in the
reconstruction of neutron dose using survey
data appropriate? (§3.2.2)

co


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number:

Claim Number:

Date:

Page of

Description of Technical Elements of Review

Yes/No/
NA

Comments

———
Tnitial

Photon Dose Conversion to Organ Dose:
Are assumptions used to convert monitored
photon dose to organ dose appropriate?
(84.1.1)

C.A5.b

Are assumptions used to covert
survey/source term data associated with
photon dose to organ dose appropriate?
(84.1.2)

C.1S.c

Are assumptions used in the energy
simplification of ICRP 74 dose conversion
factors for input into NIOSH-IREP
appropriate? (§4.1.3)

C15.

Are assumptions regarding uncertainty
associated with the energy simplification
process appropriate? (§4.5.1)

C15.

Are conservative (claimant friendly)
assumptions used in the conversion of
photon dose to organ dose?

CASA

Are conservative (claimant friendly)
assumptions used in determining the
uncertainty resulting from the energy
simplification process?

C16
C.1.6.a

Neutron Dose Reconstruction Using
Monitoring Data:
Are assumptions used in the determination

of neutron dose/neutron energy using
personal monitoring data (dosimeters)
appropriate? (§2.2.1)

C.1.6.b

‘Are assumptions used in the deterinination
of uncertainty associated with neutron
personal monitoring data appropriate?
(§2.2.1.3)

nnn

C8


Force at U.S. Nuclear Power Plants," AIF/NESP-028, May 1984. This experience has many
similarities to the development of worker and site profiles.

SC&A developed for the nuclear power industry methods for predicting worker doses. The
objective was to determine how accurate are current state-of-the-art estimates, and to develop a
method which improves the accuracy of these estimates. Initially, using data collected from
representative nuclear power plants, estimated doses were compared with actual doses in an
attempt to explain the reasons for discrepancies. The results of these comparisons were used to
guide the development of a method to improve the accuracy of these estimates.

The developed method comprises three building blocks--an overall logic, checklists, and
worksheets. A logic diagram guides the estimator through a series of steps, each of which
involves the completion of a checklist or worksheet. The checklist systematically solicits the
information needed to prepare the estimate, including appropriate adjustment factors. The
worksheets are used to organize information and perform calculations needed to construct the
dose estimate. The final report described the application of the method to the engineering design
process, and presented a sample problem which illustrates its application.

The report was published as AIF/NESP-039, Estimating Doses in Nuclear Facilities with
Emphasis on the Design Process, January 1987. The method was also programmed for
implementation on a desk-top computer. The program is contained on a floppy disk included
with the program description in NUMARC/NESP-001, DOSES: A System for the Personal
Computer to Estimate Radiation Exposure at Nuclear Facilities.

Though these investigations were performed on behalf of NRC and its licensees many years
ago, the experience and lessons learned have applicability to historical exposures
experienced by workers at DOE and AWE facilities at that time.

SC&A is currently supporting NRC's effort to develop the technical basis for a rulemaking
establishing residual radioactivity contamination standards for the clearance of materials and
equipment from licensed facilities. SC&A is characterizing the quantities and radiological
composition of materials and equipment that may be affected by the rule, and supporting the
development of cost models for use in determining material dispositions for the collective
dose/risk assessment and the cost/benefit analysis portion of the Regulatory Impact Analysis.

As part of the characterization investigations, SC&A was instrumental in the development of a
database characterizing the quantities, types, and radionuclide composition of systems, facilities,
and equipment for more than 11,000 facilities in a number of industrial and government sectors.
SC&A is currently working on two follow-on contracts. The first is to finalize NUREG-1640,
entitled “Radiological Assessments for Clearance of Equipment and Materials from Nuclear
Facilities,” for the Office of Nuclear Regulatory Research. NUREG-1640 contains methods for
translation of concentrations of radioactivity in or on certain metals and concrete into radiation
doses as a result of decontamination and survey of these materials. SC&A is performing an
analysis of individual dose assessments for the clearance of materials and equipment, resolving
public comments on NUREG-1640, and preparing the manuscripts and other materials for final
publication. Under the second contract, SC&A is providing technical assistance for both

SC&A 5-3 Sol. No. 2003-N-00768


APPENDIX B

CONFLICT OF INTEREST FORMS


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

Audit Number: Claim Number: Date: Page of
Area of | Description of Technical Elements of Review | Yes/No/ Comments Initials,
Review NA
C. EXTERNAL DOSE REVIEW PROCESS
C.1 External Dose Estimate Assumptions: Evaluate whether all assumptions used in the external dose

determination are appropriate for a remedial compensation program and determine whether, if, and to
what extent the benefit of the doubt was resolved in favor of the claimant. (Parenthetical number represents
the section within the “External Dose Reconstruction Implementation Guideline” (OCAS-IG-001) that provides
detailed methodology for conducting the appropriate portion of the dose reconstruction.)

Cl

Are assumptions used in the initial dose
assessment (rough estimate of exposure) for
determining whether the case falls into a very
low or very high potential exposure category
appropriate? (§1.4)

C12

Are assumptions used in the initial dose
assessment conservative (claimant friendly)?

C13
C.L3a

Photon Dose Reconstruction Using Monitoring
Data:
Are assumptions used in the determination
of photon dose/photon energies using
monitoring data (i.e., dosimeters)
appropriate? (§2.1.1)

C.1.3.b

Are assumptions used in determining
dosimeter dose uncertainty associated with
photon exposure appropriate? (§2.1.1.3)

C.i3.¢

Are assumptions used to determine dose for
incomplete/missing photon monitoring
records appropriate? (§2.1.2)

C13.d

Are assumptions used in calculating
uncertainty associated with
incomplete/missed photon monitoring dose
appropriate? (§2.1.2.4)

C.13.e

Are assumptions used in the determination
of the occupational medical dose
component of photon dose/photon energies
appropriate? (§2.1.3)

C5



significant inventory of factory-calibrated field sampling devices and health and safety
equipment is maintained at the laboratory. This inventory includes a full complement of
radiation survey equipment, including alpha scintillation probes, beta/gamma survey meters, and
gamma scintillation probes. The laboratory is pre-qualified with the U.S. Army Industrial
Operations Command under the category of “Characterization and Verification.” The laboratory
holds a radioactive materials license (No. 1150) with the Office of Radiation Control in the
Alabama Department of Public Health and is certified in several other states to characterize
radioactive waste.

SC&A also operates a regional office in St. Louis, Missouri, which provides quality assurance
and auditing services.

4.2.2 Graphic and Reproduction Facilities

SC&A’s production department creates a wide range of documents, presentations, and exhibit
materials. Our word processing and graphics capabilities include state-of-the-art desktop
publishing software, enabling us to create high-quality documents in a variety of formats. Using
graphics software such as Adobe Hlustrator, Adobe PhotoShop, Microsoft PowerPoint, Aldus
PageMaker, Claris Draw, Corel Draw, and T/Maker ClickArt, SC&A staff are also able to
illustrate documents and create effective presentation and exhibit materials.

The McLean office of SC&A is equipped with two Canon ImageRunner 550 reproduction
machines, one of which is networked for access from the individual workstations. These high-
volume copiers produce high-quality copies at rates of up to 83 copies per minute and are used
for reproduction of technical reports, manuals, and handbooks. They are equipped with
automatic feed and sorters, and can produce double-sided copies. Both machines are maintained
by factory-trained technicians and are serviced regularly. SC&A maintains a full complement of
laser and inkjet color and black-and-white printers.

SC&A 4-27 Sol. No. 2003-N-00768


. NESHAPS Background Information Document on Rulemaking for NRC and
Agreement State Licensees other than Nuclear Power Reactors, 430-R-92-011

. Radiation and Mixed Waste Incineration Background Information Document,
520/1-91-010

5.6 Selected Private Sector Experience

Starting with the most recent, the following presents brief descriptions of SC&A’s experience in
deriving cleanup standards using a broad range of dosimetric models and designing and
implementing facility and site characterization and closeout surveys for the private sector. All
field work is performed by SC&A personnel, using SC&A equipment, and all laboratory work is
performed by SC&A’s radiological laboratory.

New Jersey Industrial Sites

SC&A is currently involved with five New Jersey sites that are contaminated with radioactivity,
including U-238, Th-232, Ra-226, and tritium. SC&A’s role involves site investigation, waste
characterization and disposal, radiation health and safety, field procedures, oversight functions,
and assisting in the development and negotiations with NJDEP for site-specific cleanup criteria.
The New Jersey sites are located in Teterboro, Hopewell, Lodi, Riverton, and Sayreville. SC&A
has derived DCGLs for both commercial/industrial and residential uses of the sites and designed
and implemented the MARSSIM site characterization and closeout survey programs.

Curtis Bay FUSRAP Site in Baltimore, MD

SC&A served as consultant and radiological subcontractor to EA Engineering (under a contract
with the Army Corps of Engineers) to provide health physics oversight, site characterization
services, and the preparation of the baseline risk assessment of Building 23 (a large five-story
industrial building) and the Radioactive Waste Disposal Area (a seven-acre site used for waste
disposal) contaminated with residual levels of Th-232 and U-238 series radionuclides. The work
included the collection and analysis of wipe samples, air particulate samples, measurement of
direct gamma exposure rates, radon emanation analyses, and the collection and analysis of soil
samples. SC&A also monitored workers for external exposure (TLDs) and inhalation exposures
(breathing zone samplers and low volume air samplers). All work was performed by SC&A field
technicians and health physics personnel, under the direction of a Certified Health Physicist. Ail
samples were analyzed by SC&A’s radiological laboratory. All data were compiled and
reviewed under SC&A’s data verification procedures and Quality Assurance Project Plan. The
data are being used to evaluate compliance with the established radiation protection standards,
the ARARs, and to support MARSSIM evaluations.

Regulatory Approval of a Removal Action
SC&A completed a removal action for the U.S. Army Corps of Engineers (Baltimore District

under contract with Foster Wheeler Environmental Corp.) for the cleanup of the 26th Street
Disposal Site located at the Edgewood Area, Aberdeen Proving Ground, MD (Contract No.

SC&A 5-10 Sot. No. 2003-N-00768


- Dose/risk assessments for contaminated soil, aquifers, and buildings at
major DOE facilities as part of SC&A’s support to EPA in the
development of a site cleanup rule.

- Dose/risk assessment of residual radioactivity and cleanup needs for the
Republic of the Marshall Islands.

Mixed Waste Studies

Most of the studies described above involved the evaluation of both radioactive
and chemically hazardous waste. However, several SC&A studies were directed
specifically at mixed waste and mixed waste risk assessment. One of the more
challenging risk assessment projects was the development of a mixed waste
Hazard Ranking System (HRS), which was incorporated into the HRS in revised
40 CFR 300.

Airbome Pathways Risk Assessment and Source Term Characterization
These studies include:

- Radiological dose/risk assessments of airborne emissions from hundreds
of facilities throughout the United States, including DOE facilities, in
support of the radionuclide NESHAPS rulemaking.

- Inspection of several DOE facilities for compliance with the radionuclide
NESHAPS. Although this did not involve the performance of risk
assessments, SC&A did gather data pertinent to developing the source
term for risk assessments.

- The performance of radiological impact assessments as part of NEPA
documentation.

- Phase 1 of the dose reconstruction project of the Idaho National
Engineering Laboratory (INEL) for the CDC. The project involved
gathering, reviewing, abstracting, and creating a bibliographic database for
all reports, records, and data pertinent to the performance of a dose
reconstruction at INEL.

~ Reconstruction of the airborne emissions and radiation exposures
associated with INEL operations.

Aquatic (Surface Water) Pathways Dose/Risk Assessment
In addition to the assessment of surface water pathways performed in support of

RI/FS reviews, SC&A performed several special risk assessments studies
specifically for the surface water pathways, including:

SC&A

5-12 Sol. No. 2003-N-00768


4.2.1 Office and Electronic Communications Facilities

SC&A maintains its corporate headquarters in 4,200 square feet of prime office space located on
Old Dominion Drive in McLean, Virginia. This office has a 15-workstation 10/100 RJ-45 LAN,
allowing SC&A employees to work together and communicate effectively with clients and
subcontractors. The LAN operates using Windows NT 4.0 and Linux servers, and utilizes Send
Mail for electronic mail. Automated tape backup systems safeguard the network. Each
workstation has access to full-time, real-time, full-service direct connectivity over the LAN to the
Internet via our dedicated DSL line. This ensures reliable access to global Internet resources, as
well as providing the capability for communication and file transfer with remote staff,
subcontractors, and clients. Physical resources include a conference room complete with
audiovisual equipment. The building has a multi-level security system with card reader access

entry.

SC&A’s Southeastern Environmental Laboratory is located in Montgomery, Alabama and
specializes in the analysis of radionuclides in environmental media. It is fully equipped with
modern, industry-standard radiochemical and radiometric equipment and is organized according
to nationally and internationally accepted radioanalytical and treatment processing principles. A

SC&A 4-26 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

ee

Audit Number: Claim Number:

Date: Page of

—I|

—
Area of
Review

Description of Technical Elements of Review

Yes/No!
NA

B. WORK HISTORY INTERVIEW AND CLAIMANT DO!

JCUMENTATION REVIEW PROCESS

‘Comments =

B.1 _Interview/Claimant Documentation: Evaluate whether NIOSH appropriately addressed all of the reported

work history and events represented by the claimant
occurrences, (b) actual monitoring practices, (c) personal pro’

including but not limited to (a) incidents or

tection practices, and (d) work practices.

B.1.1

Did NIOSH compare the dates of employment
at all applicable facilities provided by the
claimant to those reported by DOE/Contractor
or AWE site records?

Did NIOSH compare the locations of
employment throughout the work history as
declared by the claimant to those reported by
DOE/Contractor or AWE site records?

7

Did NIOSH review site profile data/facility
records to identify radiation incidents (such as
contamination or over-exposures) declared by
the claimant?

Did NIOSH compare radiation monitoring
practices (such as monitoring frequency,
bioassay monitoring programs, etc.) as
described by claimant to facility monitoring
procedures/records?

BAS

Were facility records associated with personal
protection practices (e.g., the use of shielding,
glove boxes, respirators, etc.) compared to
those described by claimant?

B16

Did NIOSH compare work practices as
described by the claimant to site profile
data/facility records?

B17

Did NIOSH review worker/facility data to
identify work-required medical screening x-rays
records declared by the claimant?

C3


SC&A 425 Sol. No. 2003-N-00768


BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST

=

Audit Number:

Claim Number:

Date:

Page

of

Area of
Review

Description of Technical Elements of Review

Yes/No/
NA

Comments

Initials,

C.19.a

Electron Dose Reconstruction Using
Monitoring Data:
Are assumptions used in the calculation of
electron dose using dosimeters appropriate?
(§2.3.1)

C.1.9.b

‘Are assumptions used in the uncertainty
analysis for the beta dosimetry results
appropriate? (§2.3.1.3)

C.1.9.¢

Are assumptions used to calculate dose for
incomplete/missing electron monitoring
records appropriate? (§2.3.2)

C.1.9.d

Are assumptions used in determining the
uncertainty associated with
incomplete/missed electron monitoring dose
appropriate? (§2.3.2.3)

C19.

Are assumptions used in the dose
calculation from skin contamination
appropriate? (§2.3.3.2.2)

C1OF

Are assumptions used in determining
uncertainty associated with the calculation
of dose from skin contamination
appropriate? (§2.3.3.3)

C19g

‘Are assumptions used in calculating dose
from electron exposure and associated
uncertainty conservative (claimant
friendly)?

C.1.10
C.1.10.a
it

Electron Dose Reconstruction With NO

Monitoring Data:
Are assumptions incorporated in the
reconstruction of electron dose using co-
worker data appropriate? (§3.3.1)

C-1l



Tr ————

BASIC INDIVIDUAL DOSE RECONSTRUCTION REVIEW CHECKLIST
‘Audit Number: Claim Number: Date: Page of
L |
| ‘Area of | Description of Technical Elements of Review | Yes/No/ ‘Comments Tnitials
Review NA
C13E ‘Are assumptions used in determining

uncertainty associated with the occupational
medical dose component of photon
dose/photon energies appropriate?
(§2.1.3.3)

C.i3.g Are assumptions used in the calculation of
the environmental dose component of
photon dose appropriate? (§2.1.4)

C.13.h Are assumptions used in determining
uncertainty for the environmental dose
component of the photon dose calculation
appropriate? (§2.1.4.3)

C134 Are conservative (claimant friendly)
assumptions used in the determination of
photon dose/photon energies, when
monitoring records were available? |

C13, Are conservative (claimant friendly)
assumptions used to determine uncertainty
associated with photon dose, when.
monitoring records were available?

C.1.4 "  |Photon Dose Reconstruction With NO {

C.1.4.a _|Monitoring Data:
‘Are assumptions incorporated in the

reconstruction of photon dose using co-
worker data appropriate? (§3.1.1)

CA14b Are assumptions for the uncertainty analysis
associated with reconstructing photon dose
using co-worker data appropriate?
(§2.1.1.3)



in extensive hearings (each lasting about 2 weeks), where the results of our work were presented
and litigated. Our support to the People of the Marshall Islands also included participation in
periodic meetings with the DOE and the Department of the Interior. At these meetings, SC&A
presented the findings of our investigations, reviewed the work performed by DOE on behalf of
the Marshall Islands, suggested new areas of inquiry, and assisted in the drafting of memoranda
of understanding between the Republic of the Marshall Islands and the U.S. Government.

Our work involved numerous visits to Majuro, the capital of the Marshall Islands, and the outer
islands to obtain information and present our results to the people of the northern atolls, the
President and his Cabinet, the Senators representing the atolls, and before the Nitijela (the
Parliament).

5.5 Dose Assessment Support to the Environmental Protection Agency

SC&A has supported EPA/ORIA in many of its rulemaking efforts related to the nuclear power
industry and related radiation programs, including a multi-task contract. These efforts involved
the recycling of radioactive scrap metal (RSM), cleanup criteria for sites contaminated with
radioactivity, 40 CFR Part 197 regulations for Yucca Mountain, disposal of low-activity
radioactive waste, and drinking water protective action guidelines. SC&A investigated the
technical issues associated with the rules and compiled the information into formats required by
the regulatory process, including Technical Support Documents (TSDs), Background Information
Documents (BIDs), Regulatory Impact Analyses (RIAs), Environmental Impact Statements
(EISs) and Regulatory Issues Papers.

SC&A prepared the radiological dose assessment guidance provided in EPA’s “Risk Assessment
Guidance - Human Health Evaluation Manual,” which is EPA’s guidance for deriving DCGLs,
along with “Guidance for the Development of Derived Concentration Guideline Levels for
Radionuclides in Soils: Technical Background Document,” prepared for the EPA ORIA,
Contract No. 68D20155, Work Assignment 5-23, EPA Work Assignment Manager Michael
Boyd, September 30, 1997. .

SC&A support included heiping establish the framework and overall EPA strategy for
rulemaking; evaluating the legal and regulatory framework within which rules would be
promulgated; considering the scope and alternative forms of rules; generating factors involved in
implementation of rules; and analyzing precedents established by EPA and other Federal and
state agencies. Once information on the rules or guidance was published, SC&A supported EPA
in managing, evaluating, and responding to comments.

For example, SC&A prepared a comprehensive multi-volume Background Information
Document for the Agency’s proposed rule regarding the recycling of radioactive scrap metal
(RSM) cleared from nuclear facilities. The investigations (1) compiled an inventory of DOE's
existing RSM and predicted the quantity of material that would be generated through DOE's
decontamination and decommissioning (D&D) program, (2) performed a cost/benefit analysis for
all of DOE's recycle options, and (3) assessed the impacts on certain sensitive industries of
recycling metals with residual levels of radioactivity.

SC&A 5-8 Sol. No. 2003-N-00768


DACA31-94-D-0020). The project included the segregation and removal of 611 cubic yards of
waste containing elevated levels of radioactivity (depleted and natural uranium, cobalt-60,
strontium-90, cesium-137, radium-226, and thorium-232, among others), UXO, surety agents,
and hazardous waste. All waste was characterized, deposited into containers, and shipped to
Envirocare for disposal. The work was conducted under a license and oversight of the NRC,
Maryland Department of Environmental Conservation, and DOD’s Directorate of Safety, Health
and Environment. The project was audited by the NRC twice and once by the Maryland
Department of the Environment; the agencies did not issue any citations.

Upon completion of all remedial activities, SC&A implemented a final site characterization
survey and prepared a closure report to support an application to the NRC for unrestricted
release. The NRC conducted an independent radiological survey of the site via ORISE. The
survey included in situ measurements and soil sampling and analysis. The NRC authorized the
release of the site for unrestricted use on June 22, 1998. a

5.7 Dose Assessment Experience

Since its incorporation in 1981, SC&A has performed over 500 studies which required the
assessment of the radiation doses associated with radionuclides in the workplace and the
environment. In the process, SC&A has either used or reviewéd virtually every radiological dose
assessment model developed and has also developed its own models for specific purposes. The
following outlines the range of SC&A’s dose assessment experience:

. Dose/Risk Assessments in Support of Site Cleanup

SC&A studies pertaining to dose/risk assessments in support of site cleanup
include:

- The development of guidelines and regulations pertaining to the cleanup
and assessment of sites and facilities contaminated with radioactive and
mixed waste.

- The performance of baseline risk assessments at several sites, including
Weldon Springs, Kerr McGee, and Maxey Flats.

- The evaluation of the costs and benefits of cleanup technologies.

- The review of the dose/risk assessments and the models and data used to
perform the risk assessments at several sites, including waste management
units at Savannah River, Oak Ridge, Paducah, Fernald, Mound, and Los
Alamos.

- A comprehensive dose/risk assessment of sites throughout the country
containing elevated levels of naturally occurring radionuclides.

SC&A S-11 Sol. No. 2003-N-00768